Need help with Root Cause Analysis for BRC NCR

Hi Everyone,

 

We have finished our BRC audit and I am just closing the last of our NCRs. I need some help with the root cause analysis. The NCR is for a gap in our line between two machines. We bottle wine and between our rinser and our capper there is a cover, but not sufficient enough for BRC. I am struggling to do a root cause analysis as we deem it sufficient, we are replacing the cover though. Does anyone have any ideas?

 

much appreciated

reewel

Hi Reewel

Very interesting finding. Can you please give the exact wording of the non-conformance.

I am also in the wine industry and we have a cover over the line between the rinser and filler, the filler is an enclosed unit and then a cover over line between filler and capper. If was always sufficient for the BRC auditor to prevent foreign body contamination.

Winegum

What justification did the auditor use for the NC?  Did they say "This is not sufficient because..."

 

If it's standard practice in the industry you can try to argue the NC to have it removed.

Thank you for your replies,

 

So the production manager took the auditor for the tour of the production area, I was not part of that, and he told me the wrong line. So on closer inspection there is a gap in the conveyor. The rinser/filler and capper/corker are enclosed units, however there is no roof on them. We have conveyor covers from the rinser through to the filler, but there is a section missing from the filler to the capper/corker.

To be honest, I have never picked up on that before as I am slightly new here and I just assumed the machines were enclosed with roofs.

So the actual NC is written as ‘Gaps in the line covers between rinser and capper/corker over fillers’ which is fair enough. I’m still not sure of the root cause analysis. Does anyone have any input?

 

thanks in advance.

 

Rewel

Rewel,

 

Root Cause Analysis does not have to be complicated and in my experience with BRC can be quite innocent. I have not worked in your industry, but have had various minor points arise before with a simple explanation. Could it be simple, along the lines of

 

....the factory is inspected for fabrication issues and the enclosure as a whole has always been in sound condition, additionally there have been no foreign body concerns or issues raised from the line to investigate further, risk assessments have not highlighted a concern at this point and the line has been in successful operation without failure for "x amount of time". In this scenario this element has not been raised in the past and has not required further action to cover the line.

 

Or something like that, of course the corrective action would include the fact that it has been covered/will be covered and perhaps if there is requirement monitored as part of the housekeeping/fabrication type inspections.

Hi Rewel

 

This document might be of some help?

 

Minnie

Hi rewel,

 

I assume the NC was due to lack of product protection from possible env. etc contamination, (or the reverse ?)

I assume the gap was by design

Data is lacking

 

As i understand, the preferred target for a RC is a "system" deficiency.

 

IMO a large number of causal chains are possible. i postulate one -

 

Problem - Potential Contamination Risk

Cause - Inadequate Hygienic Equipment Construction due Y

Cause - Inadequate Hygienic Design due X

 

RC - Training

 

Production and/or Engg would probably have a different viewpoint. >>>>>> QA.

 

PS - i noticed the BRC Guidance chooses to Personalise the RC. Slippery Slope.

Hi Rewel

Agree with Charles, the cause is inadequate hygiene construction and design. Oversight during risk analysis and verification of flow diagram?

I would also suggest that you give evidence that you have reviewed the complete flow process to ensure that no contamination can happen at other stages with open product, from empty bottles after rinsing to filled products before capping. Include photos, documentation as evidence.

Regards

Wine Gum